Life Cycle of a Private Foundation - Private Letter Rulings

The IRS will rule on the tax consequence of proposed changes to a foundation's purposes or activities. Thus, if you are unsure about whether proposed changes are consistent with your status as a section 501(c)(3) organization, you may want to request a private letter ruling or determination letter. Revenue Procedure 2013-4 (or latest update) provides procedures for such requests.

In some areas, the law requires that an organization notify the Internal Revenue Service or receive an advance determination before undertaking a transaction resulting in certain tax consequences. Thus, a foundation must request a private letter ruling or determination with respect to the following issues: